Prudential Regulatory Measures1 in Response to COVID-19 (as of September 30, 2020)

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Prudential Regulatory Measures1 in Response to COVID-19 (as of September 30, 2020)
                                                                                                                    * indicates no recent updates

                                                                                                                               Provisioning, Definition of
                                                                                                                                                                   Consultations/                      Other (reporting, stress
     Jurisdiction                                Capital                                          Liquidity                     Default and NPL-related
                                                                                                                                                              Implementation Timetables                 testing, conduct, etc.)
                                                                                                                                       measures
    FSB                      March 20: FSB encouraged local                         March 20: FSB encouraged use of        *                                 April 2: FSB issued a statement       April 1: The G20 Finance Ministers
                             authorities to support use of                          liquidity buffers to support clients                                     summarizing its coordination          and Central Bank Governors
                             capital buffers by banks to extend                     and ensure functioning of                                                activities, its work on assessing     published a release following their
                             credit. The FSB also announced                         markets.                                                                 financial vulnerabilities and         virtual meeting on March 31
                             coordination efforts among                             July 15: FSB supported the BCBS                                          setting out its re-prioritized 2020   setting out a range of measures
                             authorities.                                           statement on buffer usage and                                            work program and the criteria         including working with the FSB in
                             July 15: FSB supported the BCBS                        announced that supervisors have                                          under which this prioritization is    coordination of regulatory policy
                             statement on buffer usage and                          agreed that banks will be given                                          being determined.                     responses.
                             announced that supervisors have                        sufficient time to restore buffers,                                      September 7: FSB extended the         April 11: FSB issued a letter to
                             agreed that banks will be given                        taking into account economic and                                         implementation dates by one year      G20 finance ministers and central
                             sufficient time to restore buffers,                    market conditions and                                                    for its policy recommendations        bank governors on its vision for
                             taking into account economic and                       individual bank circumstances.                                           related to minimum haircut            post-COVID-19 recovery, including
                             market conditions and                                                                                                           standards for non-centrally           evaluating the effects of reforms
                             individual bank circumstances.                                                                                                  cleared securities financing          and facilitating a smooth
                                                                                                                                                             transactions.                         transition from LIBOR.
                                                                                                                                                                                                   April 15: FSB published a report
                                                                                                                                                                                                   summarizing the principles
                                                                                                                                                                                                   guiding its COVID-19 work, the
                                                                                                                                                                                                   key response measures taken to
                                                                                                                                                                                                   date, financial stability
                                                                                                                                                                                                   implications and future work.

1
 This document captures prudential, securities and related regulatory measures adopted internationally. It does not capture fiscal, monetary and related measures. For access to an IIF compilation of
such measures please follow this link: https://www.iif.com/covid-19 and then navigate to the “COVID-19 Global Policy Response Summary.”

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Provisioning, Definition of
                                                                                                                                             Consultations/            Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables       testing, conduct, etc.)
                                                                                                                  measures
                                                                                                                                                                    April 15: G20 Finance Ministers
                                                                                                                                                                    and Central Bank Governors
                                                                                                                                                                    published a communique in which
                                                                                                                                                                    they committed to use their
                                                                                                                                                                    power to support the economy
                                                                                                                                                                    during COVID-19 and stated their
                                                                                                                                                                    support of the financial measures
                                                                                                                                                                    countries have taken in response
                                                                                                                                                                    to the pandemic.
                                                                                                                                                                    May 26: FSB, in cooperation with
                                                                                                                                                                    BCBS, CPMI, IAIS and IOSCO held a
                                                                                                                                                                    meeting with public and private
                                                                                                                                                                    participants and discussed the
                                                                                                                                                                    effectiveness of prudential and
                                                                                                                                                                    other financial policy measures
                                                                                                                                                                    taken to date, including
                                                                                                                                                                    experiences with their
                                                                                                                                                                    implementation. They also
                                                                                                                                                                    discussed policy issues going
                                                                                                                                                                    forward.
                                                                                                                                                                    July 1: FSB released a statement
                                                                                                                                                                    on the impact of COVID-19 on
                                                                                                                                                                    global benchmark reform.
                                                                                                                                                                    July 15: FSB published a letter
                                                                                                                                                                    from the Chair and a report to
                                                                                                                                                                    G20 Finance Ministers and
                                                                                                                                                                    Governors on the financial
                                                                                                                                                                    stability implications of, and
                                                                                                                                                                    policy measures taken in response
                                                                                                                                                                    to, the COVID-19 pandemic.

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Provisioning, Definition of
                                                                                                                                                                 Consultations/                    Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                  Default and NPL-related
                                                                                                                                                            Implementation Timetables               testing, conduct, etc.)
                                                                                                                                measures
BCBS                     March 20: BCBS announced its                           March 20: BCBS supported use of       April 3: BCBS published guidelines   March 20: BCBS said it              April 8: BCBS will not collect Basel
                         support for use of capital buffers                     liquidity buffers and encouraged      on including the risk-reducing       temporarily suspended all open      III monitoring data for the end-
                         by banks to accommodate credit                         the use of HQLA stocks.               effect of measures banks have        consultations and postponed         June 2020 reporting date to
                         and absorb losses during the                           June 17: BCBS discussed the           taken in response to COVID-19        jurisdictional assessments for      increase operational capacity for
                         crisis.                                                impact of COVID-19 and                when calculating regulatory          remainder of 2020.                  banks.
                         June 17: BCBS discussed the                            reiterated guidance on liquidity      capital requirements.                March 27: BCBS announced the        September 25: BCBS approved an
                         impact of COVID-19 and                                 buffers. They also stated that        Additionally, BCBS will amend its    deferral of the Basel III           updated workplan to evaluate its
                         reiterated guidance on capital                         supervisors will provide banks        transitional arrangements for the    implementation deadline by one      post-crisis reforms, which will
                         buffers. They also stated that                         sufficient time to restore buffers,   regulatory capital treatment of      year to January 1, 2023. The        incorporate lessons learned from
                         supervisors will provide banks                         taking into account economic and      ECL accounting.                      deadlines for the revised market    the COVID-19 crisis.
                         sufficient time to restore buffers,                    market conditions and individual                                           risk framework and revised Pillar
                         taking into account economic and                       bank circumstances.                                                        3 disclosure requirements have
                         market conditions and individual                       September 25: BCBS reiterated its                                          also been pushed to January 1,
                         bank circumstances.                                    previous guidance to make use of                                           2023.
                         September 25: BCBS reiterated its                      the Basel III capital and liquidity                                        April 3: BCBS will defer the
                         previous guidance to make use of                       buffers.                                                                   implementation of the revised G-
                         the Basel III capital and liquidity                                                                                               SIB framework by one year, from
                         buffers.                                                                                                                          2021 to 2022.
                                                                                                                                                           April 3: BCBS and IOSCO have
                                                                                                                                                           agreed to extend the deadline for
                                                                                                                                                           completing the final two
                                                                                                                                                           implementation phases of the
                                                                                                                                                           margin requirements for non-
                                                                                                                                                           centrally cleared derivatives, by
                                                                                                                                                           one year to September 1, 2022.
IOSCO                    *                                                      *                                     April 3: IOSCO supported             April 3: IOSCO and BCBS have        March 25: IOSCO announced
                                                                                                                      professional judgment in applying    agreed to extend the deadline for   coordination activities with other
                                                                                                                      accounting standards rather than     completing the final two            standard setters and support for
                                                                                                                      applying in a mechanistic manner.    implementation phases of the        actions designed to maintain
                                                                                                                                                           margin requirements for non-        market efficiency, liquidity and

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Provisioning, Definition of
                                                                                                                                                     Consultations/                       Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables                  testing, conduct, etc.)
                                                                                                                    measures
                                                                                                                                               centrally cleared derivatives, by      access. Particular focus on
                                                                                                                                               one year to September 1, 2022.         operational and financial
                                                                                                                                               April 8: IOSCO has reprioritized its   resilience of FMIs and information
                                                                                                                                               work program to focus on the           flows.
                                                                                                                                               direct effects of COVID-19 on          May 29: IOSCO issued a
                                                                                                                                               market-based finance.                  statement on the importance of
                                                                                                                                                                                      disclosure concerning COVID-19
                                                                                                                                                                                      related impacts.
IASB                     *                                                      *                         March 27: IASB released a            March 27: IASB said the release of     *
                                                                                                          statement clarifying how to apply    several amendments to IFRS
                                                                                                          IFRS 9 during this time of           standards will be delayed until
                                                                                                          uncertainty. The Board also states   May 2020, though IBOR reform
                                                                                                          that it is working with regulators   work and amendments to IFRS 17
                                                                                                          in the current environment and       will proceed as planned.
                                                                                                          encourages companies to              April 10: IASB is considering
                                                                                                          consider guidance provided by        whether to propose a deferral by
                                                                                                          prudential and securities            one year of IFRS Standards,
                                                                                                          regulators.                          extending ongoing consultation
                                                                                                          April 17: IASB decided to propose    periods, and delaying publication
                                                                                                          an amendment to the leases           of new consultations.
                                                                                                          Standard, IFRS 16, to help           April 17: IASB decided to propose
                                                                                                          companies account for covid-19-      extending by one year the
                                                                                                          related rent concessions, such as    effective date of an amendment
                                                                                                          rent holidays.                       to IAS 1, extend three month of
                                                                                                                                               consultation period for three
                                                                                                                                               consultations, and defer several
                                                                                                                                               consultations for a year.
                                                                                                                                               July 15: IASB deferred by one year
                                                                                                                                               the effective date of Classification

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Provisioning, Definition of
                                                                                                                                                                 Consultations/                      Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                 Default and NPL-related
                                                                                                                                                            Implementation Timetables                 testing, conduct, etc.)
                                                                                                                               measures
                                                                                                                                                           of Liabilities as Current or Non-
                                                                                                                                                           current within IAS1.

FATF                     *                                                      *                                  *                                       April 28: FATF extended deadlines     April 1: FATF released a
                                                                                                                                                           for mutual evaluations and            statement on the efforts it has
                                                                                                                                                           follow-ups.                           taken in response to COVID-19.
                                                                                                                                                                                                 May 4: FATF released a paper on
                                                                                                                                                                                                 AML/CFT risks during the COVID-
                                                                                                                                                                                                 19 pandemic, along with
                                                                                                                                                                                                 recommended policy actions, and
                                                                                                                                                                                                 a listing of policy measures
                                                                                                                                                                                                 various jurisdictions have taken in
                                                                                                                                                                                                 response to the theat.
European                 March 12: ECB said banks can                           March 12: ECB advised it would     March 20: ECB exercised flexibility     March 12: EBA said EU stress-         March 16: ESMA temporarily
Union                    fully use capital buffers and that                     allow banks to operate             regarding the classification of         tests have been postponed to          lowered the reporting threshold
                         banks will benefit from relief in                      temporarily below the liquidity    debtors as “unlikely to pay” on         2021. In 2020, the EBA will           for holders of net short positions
                         the composition of capital for                         coverage ratio.                    public guarantees granted.              instead carry out an additional       in shares traded on an EU
                         Pillar 2 Requirements. Banks are                       July 28: ECB committed to allow    March 20: ECB recommended               EU-wide transparency exercise.        regulated market.
                         also expected not to increase                          banks to operate below the LCR     that all banks avoid procyclical        March 20: ESMA extended all           March 19: ESMA set out an
                         capital distributions in response                      until at least end-2021, without   assumptions in their models to          consultation deadlines for four       approach to the Securities
                         to these measures.                                     automatically triggering           determine provisions.                   weeks.                                Finance Transactions Regulation.
                         March 27: ECB asks banks not to                        supervisory actions.               March 25: EBA released a                March 25: EBA said the deadlines      March 20: ESMA clarified its
                         pay dividends for 2019 or 2020                                                            statement on the application of         of ongoing public consultations       position on call taping under
                         until at least October 1, 2020.                                                           the prudential framework with           will be extended by two months        MIFID II.
                         Banks should also refrain from                                                            regards to classification of default,   and public hearings will be           March 27: ESMA recommended
                         share buy-backs aimed at                                                                  forbearance, and IFRS 9.                postponed.                            that Member State authorities
                         remunerating shareholders.                                                                March 25: ESMA issued guidance          March 31: EBA provides details on     accept delayed financial reports
                         March 31: EBA reiterated and                                                              on accounting principles,               its call for leeway on reporting      from issuers.
                         expanded its call to institutions to                                                      including moratoria on repayment        dates, urging one-month flexibility

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Provisioning, Definition of
                                                                                                                                                     Consultations/                        Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables                   testing, conduct, etc.)
                                                                                                                    measures
                         refrain from the distribution of                                                 of loans and the calculation of      for reports with remittance dates       March 31: ESMA encouraged
                         dividends or share buybacks for                                                  expected credit losses in            between March and the end of            national competent authorities
                         the purpose of remunerating                                                      accordance with IFRS 9.              May 2020. EBA also called for           not to prioritize supervisory
                         shareholders and assess their                                                    April 2: EBA issued guidelines on    flexibility in assessing deadlines of   action against execution venues
                         remuneration policies in line with                                               the requirements of public and       institutions’ Pillar 3 disclosures.     and firms in respect of the
                         the risks stemming from the                                                      private moratoria given COVID-19.    Also the EBA, in coordination with      deadlines of the general best
                         economic situation.                                                              April 22: EBA provided further       the BCBS, has decided to cancel         execution reports under MiFID II.
                         April 1: SRB has published                                                       clarity on the prudential            the Quantitative Impact Study           March 31: EBA, in coordination
                         commentary by its Chair which                                                    application of the definition of     (QIS) based on June 2020 data.          with the BCBS, has decided to
                         acknowledges capital relief                                                      default and forbearance as well as   April 6: European Commission            cancel the Quantitative Impact
                         measures undertaken by                                                           how the EBA Guidelines on            extended deadlines for                  Study (QIS) based on June 2020
                         Authorities in the region and                                                    legislative and non-legislative      responding to its four 2020             data.
                         states that such measures will be                                                moratoria on loan repayments         banking and finance                     April 1: SRB has published
                         taken into account in future MREL                                                apply to securitizations.            consultations.                          commentary by its Chair which
                         decisions.                                                                       June 19: European Parliament         April 9: ESMA decided to further        discusses operational relief
                         April 8: SRB provided additional                                                 approved changes to the capital      extend the response date for the        measures being adopted by the
                         clarity on its approach to                                                       requirement regulation and           consultation on the MiFID II/MiFIR      Board.
                         minimum requirements for own                                                     clarified the treatment of IFRS 9    review report to June 14.               April 7: ECB announced a series of
                         funds and eligible liabilities                                                   and expected credit loss.            April 9: ESMA postponed the             collateral easing measures to
                         (MREL), including the setting of                                                 September 21: EBA announced it       application of the annual non-          increase capacity to provide
                         MREL targets, taking the impact                                                  would phase out certain elements     equity transparency calculations        funding and liquidity.
                         of the COVID-19 crisis into                                                      of its legislative and non-          and the calculations for the            April 9: ESMA acknowledged that
                         account.                                                                         legislative loan moratoria that      systematic internalizer test for        COVID-19 has made it difficult for
                         April 16: ECB announced it will                                                  were introduced in response to       derivatives, ETCs, ETNs, emission       fund managers to file certain
                         temporarily allow lower capital                                                  COVID-19.                                                                    reports and encouraged National
                                                                                                                                               allowances and structured finance
                         requirements for market risk by                                                                                                                               Competent Authorities to adopt a
                                                                                                                                               products under MiFID II.
                         reducing the qualitative market                                                                                                                               risk-based approach and not
                         risk multiplier for six months.                                                                                       May 4: EBA, EIOPA and ESMA              prioritize supervisory actions.
                         April 22: EBA proposed to adjust                                                                                      published joint draft Regulatory        April 9: ESMA issued a statement
                         the capital impact for market risk                                                                                    Technical Standards to amend the
                                                                                                                                                                                       to promote National Competent
                                                                                                                                               Delegated Regulation on the risk

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Provisioning, Definition of
                                                                                                                                              Consultations/                      Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                         Implementation Timetables                 testing, conduct, etc.)
                                                                                                                  measures
                         by amending its standards on                                                                                   mitigation techniques for non-        Authorities regarding the
                         prudent valuation, including a use                                                                             centrally cleared OTC derivatives     timeliness of fulfilling external
                         of 66% aggregation factor until                                                                                to incorporate a one-year deferral    audit requirements for interest
                         December 31, 2020.                                                                                             of the two implementation             rate benchmark administrators
                         April 28: European Commission                                                                                  phases of the bilateral margining     and contributors to interest rate
                         proposed amendments to the                                                                                     requirements.                         benchmarks.
                         EU's banking prudential rules,                                                                                 June 18: EBA extended the
                                                                                                                                                                              April 15: ECB issued a non-
                         proposing exceptional temporary                                                                                deadline for the application of its
                                                                                                                                                                              objection decision supporting
                         measures by adapting the                                                                                       guidelines on payment moratoria
                         timeline of the application of                                                                                 by three months to September          national macroprudential
                         international accounting                                                                                       30, 2020. In addition, they           authorities’ macroprudential
                         standards on banks' capital, by                                                                                highlighted that the                  measures taken in response to
                         treating more favorably public                                                                                 implementation timeline               COVID-19.
                         guarantees granted during this                                                                                 envisaged in the EBA’s IRB            April 15: ESMA said it supports
                         crisis, by postponing the date of                                                                              roadmap to repair internal            decisions by national regulators to
                         application of the leverage ratio                                                                              models remains overall                place restrictions on short selling
                         buffer and by modifying the way                                                                                unchanged.                            and is coordinating alignment of
                         of excluding certain exposures                                                                                                                       the renewal process.
                         from the calculation of the                                                                                                                          April 22: ECB adopted temporary
                         leverage ratio.
                                                                                                                                                                              measures to mitigate the effect
                         June 19: European Parliament
                                                                                                                                                                              on collateral availability of
                         approved changes to the capital
                                                                                                                                                                              possible rating downgrades.
                         requirement regulation, including
                         the deferral of implementation of                                                                                                                    May 14: ESRB released a
                         the leverage ratio buffer to                                                                                                                         statement with a set of
                         January 2023. Although not                                                                                                                           recommended actions in five
                         mentioned in the press release,                                                                                                                      priority areas in response to
                         the draft resolution also proposes                                                                                                                   COVID-19.
                         additional flexibility to competent                                                                                                                  May 14: ESMA expressed its
                         authorities in relation to the                                                                                                                       support for ESRB’s proposal that

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Provisioning, Definition of
                                                                                                                                             Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                        Implementation Timetables        testing, conduct, etc.)
                                                                                                                  measures
                         market risk multiplier to mitigate                                                                                                         national regulators enhance
                         the negative effects of the                                                                                                                supervision of investment funds
                         extreme market volatility.                                                                                                                 with significant exposures to
                         July 9: EBA released a statement                                                                                                           corporate debt and real estate.
                         on resolution planning in                                                                                                                  May 18: ESMA noted that several
                         light of the COVID-19 pandemic                                                                                                             national regulators did not renew
                         and updated its view on MREL
                                                                                                                                                                    emergency restrictions on short
                         decisions.
                                                                                                                                                                    selling and similar transactions.
                         July 28: ECB extended its
                         recommendation that banks not                                                                                                              June 2: EBA released guidelines to
                         pay dividends until January 2021                                                                                                           address gaps in reporting and
                         and issued a letter with its                                                                                                               disclosure caused by COVID-19.
                         expectation that banks exercise                                                                                                            June 8: ESRB released a statement
                         extreme moderation on variable                                                                                                             detailing its second set of actions
                         remuneration to conserve capital.                                                                                                          in response to COVID-19,
                         July 28: ECB committed to allow                                                                                                            including a recommendation that
                         banks to operate below the P2G                                                                                                             distributions be restricted.
                         and the combined buffer                                                                                                                    June 11: ESMA renewed its
                         requirement until at least end-                                                                                                            decision to temporarily require
                         2022, without automatically                                                                                                                the holders of net short positions
                         triggering supervisory actions.                                                                                                            to notify the relevant national
                         September 17: ECB announced                                                                                                                competent authority if the
                         that it would allow banks to                                                                                                               position exceeds 0.1% of the
                         exclude central bank exposures                                                                                                             issued share capital.
                         from the leverage ratio until June                                                                                                         July 7: EBA released a report
                         27, 2021.
                                                                                                                                                                    clarifying the implementation of
                                                                                                                                                                    adjustments to the prudential
                                                                                                                                                                    framework due to COVID-19.

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Provisioning, Definition of
                                                                                                                                                           Consultations/                    Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity            Default and NPL-related
                                                                                                                                                      Implementation Timetables               testing, conduct, etc.)
                                                                                                                          measures
                                                                                                                                                                                         August 7: EBA provided clarity on
                                                                                                                                                                                         the implementation of the
                                                                                                                                                                                         reporting and disclosure
                                                                                                                                                                                         framework in the context of
                                                                                                                                                                                         COVID-19 measures.
                                                                                                                                                                                         August 11: EBA published
                                                                                                                                                                                         guidance on the impact of CRR
                                                                                                                                                                                         adjustments in response to the
                                                                                                                                                                                         COVID‐19 pandemic on
                                                                                                                                                                                         supervisory reporting and
                                                                                                                                                                                         disclosure.
                                                                                                                                                                                         August 14: EBA updated its work
                                                                                                                                                                                         program for 2020 in light of the
                                                                                                                                                                                         COVID-19 pandemic.
                                                                                                                                                                                         September 17: ESMA renewed its
                                                                                                                                                                                         decision to temporarily require
                                                                                                                                                                                         the holders of net short positions
                                                                                                                                                                                         to notify the relevant national
                                                                                                                                                                                         competent authority if their
                                                                                                                                                                                         position exceeds 0.1% of the
                                                                                                                                                                                         issued share capital.
                                                                                                                                                                                         September 30: EBA published its
                                                                                                                                                                                         work program for 2021, including
                                                                                                                                                                                         work to address the effects of
                                                                                                                                                                                         COVID.
United States            March 17: FRB, FDIC, and OCC                           March 17: FRB, FDIC, and OCC    March 19: The FDIC Chairman          March 24: FRB stated that it will   March 24: FRB announces
                         encouraged banks to use their                          encouraged banks to use their   asked FASB to delay transitions to   grant firms additional time to      adjustments to its supervisory
                         capital buffers and issued an                          liquidity buffers.              certain accounting rules including   resolve non-critical existing       approach with increased

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Provisioning, Definition of
                                                                                                                                                                  Consultations/                     Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                  Default and NPL-related
                                                                                                                                                             Implementation Timetables                testing, conduct, etc.)
                                                                                                                                measures
                         interim final rule to introduce a                      April 23: FRB announced               those related to CECL and TDR         supervisory findings, but CCAR       monitoring and outreach and
                         technical change to make any                           temporary measures to help            classifications.                      capital plans should still be        reduced examination activities,
                         automatic limitations on capital                       increase the availability of          March 22: FRB, CSBS, CFPB, FDIC,      submitted by April 6.                especially for small financial
                         distributions more gradual.                            intraday credit by suspending         NCUA, and OCC announced they          March 31: FRB said it would delay    institutions.
                         March 23: FRB issued an interim                        uncollateralized intraday credit      will not direct institutions to       the effective date for its revised   March 24: FRB delayed the
                         final rule to introduce a technical                    limits and permitting a               automatically categorize loan         control framework by six months.     implementation of changes to
                         change to make any automatic                                                                 modifications as troubled debt        April 2: FRB, FDIC, OCC, SEC, and    procedures governing the
                                                                                streamlined procedure for
                         limitations on capital distributions                                                         restructurings.                       CFTC said they would consider        provision of intraday credit to U.S.
                                                                                secondary credit institutions to
                         under the TLAC rule more                                                                     March 27: FRB, FDIC, and OCC          comments on their proposal to        branches and agencies of foreign
                                                                                request collateralized intraday       announced an interim final rule       update the Volcker Rule’s covered    banking organizations by six
                         gradual.                                               credit.
                         March 27: FRB, FDIC, and OCC                                                                 that would provide flexibility to     funds provision until May 1, a       months.
                                                                                May 5: FRB, FDIC, and OCC             allow banks to mitigate the           month later than originally          March 25: SEC has extended
                         said they would allow early
                                                                                announced an interim final rule to    effects of CECL.                      announced.                           certain reporting deadlines for
                         adoption of SA-CCR.
                         April 1: FRB announced a                               adjust the Liquidity Coverage         April 7: SEC said that financial      April 10: CFTC announced it          public companies and issued
                         temporary change to its                                Ratio for banks participating in      institutions that take advantage of   would extend deadlines for           guidance on COVID-19 related
                                                                                the Money Market Mutual Fund          the CARES Act provision that          certain open consultations.          disclosures.
                         supplementary leverage ratio
                                                                                Liquidity Facility and the Paycheck   allows the deferral of                April 27: FRB and FDIC announced     March 31: CFTC has issued no-
                         rule, which would exclude U.S.
                                                                                Protection Program Liquidity          implementation of two GAAP            that they would extend the           action relief to foreign affiliates of
                         Treasury securities and deposits                                                             standards will not be in violation                                         certain futures commission
                                                                                Facility.                                                                   comment period for their
                         at Federal Reserve Banks from the                                                            of GAAP.                                                                   merchants affected by COVID-19,
                                                                                                                                                            proposed guidance for large
                         calculation of the rule for holding                                                          April 22: OCC, FRB, and FDIC                                               which will last until September 30.
                                                                                                                                                            foreign banks’ resolution plans by
                         companies until March 31, 2021.                                                              announced a final rule with                                                April 8: SEC issued a statement on
                                                                                                                                                            30 days.
                         April 6: FRB, FDIC, and OCC                                                                  changes to the interim final rule                                          the importance of robust
                                                                                                                                                            May 6: FRB and FDIC extended
                         announced two interim final rules                                                            of March 27 on CECL                                                        disclosures and reporting during
                         for community banks, including a                                                                                                   the deadlines for two resolution
                                                                                                                      implementation.                                                            COVID-19.
                         change to the community bank                                                                                                       plan requirements.                   April 14: FRB, FDIC, OCC, NUCA,
                         leverage ratio.                                                                                                                    May 28: CFTC approved an             and CFPB issued an interim final
                         April 7: FRB, OCC, FDIC, CFPB and                                                                                                  interim final rule to grant an       rule to temporarily defer real
                         NCUA issued a revised                                                                                                              extension of the compliance          estate-related appraisals and
                         interagency statement on loan                                                                                                      schedule for initial margin          evaluations and related reporting

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Provisioning, Definition of
                                                                                                                                              Consultations/                   Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity    Default and NPL-related
                                                                                                                                         Implementation Timetables              testing, conduct, etc.)
                                                                                                                  measures
                         modifications. The statement                                                                                   requirements for uncleared swaps   requirements under the agencies'
                         includes supervisory                                                                                           in response to COVID-19.           interagency appraisal regulations.
                         interpretations on past due and                                                                                June 10: CFTC extended elements    June 15: FRB announced that it
                         nonaccrual regulatory reporting                                                                                of its COVID-19 no-action relief   will resume examination activities
                         of loan modification programs                                                                                  through September 30, 2020.        for all banks, after previously
                         and regulatory capital.                                                                                                                           announcing a reduced focus on
                         April 9: FRB, FDIC, and OCC                                                                                                                       exam activity in light of COVID-19.
                         announced an interim final rule to                                                                                                                June 23: FRB, FDIC, OCC, NCUA,
                         encourage lending through the                                                                                                                     and state regulators issued
                         Small Business Administration's                                                                                                                   guidance to examiners to
                         Paycheck Protection Program                                                                                                                       promote consistency and
                         (PPP), clarifying that a zero                                                                                                                     flexibility in oversight of financial
                         percent risk weight applies to                                                                                                                    institutions affected by COVID-19.
                         loans covered by the PPP for
                         capital purposes.
                         April 30: FRB clarified that the
                         interest in a Main Street
                         loan retained by an Eligible
                         Lender should be
                         assigned the risk weight
                         applicable to the counterparty for
                         the loan in a FAQ.
                         May 15: FRB, FDIC, and OCC
                         announced an interim final rule
                         permitting depository institutions
                         to choose to exclude U.S.
                         Treasury securities and deposits
                         at Federal Reserve Banks from the
                         calculation of the supplementary
                         leverage ratio.

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                               Page 11
Provisioning, Definition of
                                                                                                                                                                    Consultations/                    Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                  Default and NPL-related
                                                                                                                                                               Implementation Timetables               testing, conduct, etc.)
                                                                                                                                measures
                         June 25: FRB decided to suspend
                         share repurchases and restrict
                         dividends for the third quarter of
                         2020.
                         September 29: FRB finalized a
                         rule to neutralize the regulatory
                         capital and liquidity effects for
                         banks that participate in certain
                         Fed liquidity facilities.
Argentina                *                                                      *                                     March 19: Central Bank of the        *                                      *
                                                                                                                      Argentine Republic arranged for
                                                                                                                      the provisional flexibility of the
                                                                                                                      parameters with which bank
                                                                                                                      debtors are classified.
Australia                March 19: APRA announced                               March 30: APRA allows                 March 23: APRA provided              March 23: APRA said it is              April 1: APRA announced changes
                         support for use of capital buffers                     authorized deposit-taking             flexibility for treatment of         suspending all prudential              to reporting obligations in
                         to promote ongoing lending to                          institutions to include the benefit   payment holidays and                 framework consultations and            response to COVID-19.
                         the economy.                                           of the Initial Allowance in the       reorganized loan repayments that     actions on all non-essential           April 1: APRA and ASIC release a
                         April 7: APRA released a                               calculation of the Liquidity          such arrangements are not            matters until at least September       letter on the impact of COVID-19
                         statement that it expects ADIs                         Coverage Ratio, Minimum               treated as in arrears or             30, 2020. The implementation           for superannuation trustees.
                         and insurers to limit discretionary                    Liquidity Holdings Ratio and Net      restructured.                        dates for recently finalized rules     April 8: APRA will suspend issuing
                         capital distributions, including                       Stable Funding Ratio from 31          July 8: APRA announced an            will be reconsidered.                  new banking or insurance licenses
                         dividends. The statement includes                      March 2020.                           extension of its temporary capital   March 23: ASIC has immediately         for at least six months.
                         guidance for determining                                                                     treatment for bank loans with        suspended a number of near-term        April 8: ASIC released feedback on
                         distributions. APRA also expects                                                             repayment deferrals, as well as      activities which are not time-         financial institutions' preparation
                         that Boards will appropriately                                                               temporarily adjusting the capital    critical, including consultation and   for LIBOR transition recognizing
                         limit executive cash bonuses.                                                                treatment of restructured loans.     reviews.                               that disruptions from the COVID-
                         May 7: APRA released an FAQ on                                                               September 9: APRA issued a letter    March 30: APRA announced it is         19 outbreak may affect the timing
                         its expectations for the regulatory                                                          outlining its response to its        deferring its scheduled

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Provisioning, Definition of
                                                                                                                                                        Consultations/                 Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                   Implementation Timetables            testing, conduct, etc.)
                                                                                                                    measures
                         capital approach for loan                                                        consultation on capital measures     implementation of the Basel III     of some aspects of institutions’
                         repayment deferrals and                                                          and reporting requirements for       reforms in Australia by one year.   transition plans.
                         clarifications on its guidance for                                               loans impacted by COVID-19.          April 16: APRA announced new        April 14: ASIC released a
                         mortgage lending.                                                                                                     commencement dates for              statement detailing how its
                         May 19: APRA published an FAQ                                                                                         prudential and reporting            regulatory work and priorities
                         on market risk capital                                                                                                standards.                          have changed in response to
                         requirements in response to                                                                                           August 10: APRA announced it        COVID-19.
                         COVID-19.                                                                                                             will recommence public              August 31: APRA has published its
                         June 17: APRA updated its FAQ to                                                                                      consultations on select policy      2020-2024 Corporate Plan, which
                         provide clarification on the                                                                                          reforms and begin a phased          has been updated to account for
                         standardized approach to credit                                                                                       resumption of the issuing of new    the substantial impact of the
                         risk-weighted assets.                                                                                                 licenses.                           COVID-19 pandemic.
                         July 29: APRA updated its capital
                         management guidance for banks
                         and insurers, easing restrictions
                         around paying dividends.
                         August 13: APRA issued a
                         consultation letter to banks
                         regarding capital measures and
                         reporting requirements for loans
                         affected by COVID-19.
Belgium                  March 11: National Bank of                             *                         April 15: National Bank of Belgium   *                                   March 13: National Bank of
                         Belgium lowered the counter-                                                     released a Q&A for credit                                                Belgium wrote to its banks
                         cyclical buffer level from 0.5% to                                               institutions on the moratorium                                           welcoming the measures of
                         0% to support banks in extending                                                 and guarantee scheme including                                           EBA/ECB and stating its intention
                         credit facilities to customers.                                                  prudential and accounting                                                to apply them in full.
                         April 1: National Bank of Belgium                                                implications.                                                            March 17: FSMA announces
                         expects banks to comply with ECB                                                                                                                          prohibition of short selling.
                         recommendation regarding                                                                                                                                  April 2: FSMA announced an
                         dividend distribution policy in the                                                                                                                       explanation regarding recording

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                    Page 13
Provisioning, Definition of
                                                                                                                                                                  Consultations/                     Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                 Default and NPL-related
                                                                                                                                                             Implementation Timetables                testing, conduct, etc.)
                                                                                                                               measures
                         context of the management of the                                                                                                                                        of telephone conversation under
                         coronavirus.                                                                                                                                                            MiFID II.
                         June 30: National Bank of Belgium                                                                                                                                       April 14: National Bank of Belgium
                         said it would keep the                                                                                                                                                  announced an extension for
                         countercyclical capital buffer at                                                                                                                                       certain reporting requirements in
                         0% in Q3.                                                                                                                                                               accordance with EU-level
                         July 30: National Bank of Belgium                                                                                                                                       changes.
                         extended its recommendation to                                                                                                                                          April 15: FSMA extended the
                         suspend dividend payments until                                                                                                                                         prohibition of short selling until
                         at least January 1, 2021 and                                                                                                                                            May 18.
                         encouraged a cautious attitude                                                                                                                                          May 18: FSMA suspended the ban
                         towards variable remuneration                                                                                                                                           on creating or increasing net short
                         and profit sharing.                                                                                                                                                     positions as of May 19.
                         September 30: National Bank of
                         Belgium kept the countercyclical
                         capital buffer at 0% and
                         maintained its expectation not to
                         increase at least until Q3 2021.
Brazil                   March 16: Banco Central do Brasil                      Late February: Banco Central do      March 16: Banco Central do Brasil      April 20: Banco Central do Brasil    *
                         reduced the Conservation Capital                       Brasil reduced the reserve           reduced provisioning rules for the     postponed the deadline of Pillar 3
                         Buffer from 2.5% to 1.25% for one                      requirement ratio on time            refinancing of certain loans for six   reporting to June 30.
                         year.                                                  deposits and increased the           months.
                                                                                amount of reserves considered
                                                                                High Quality Liquid Assets.
Canada                   March 13: OSFI lowered the                             March 27: OSFI announced             March 27: OSFI announced               March 13: OSFI said that no buffer   April 3: OSFI released a statement
                         Domestic Stability Buffer                              flexibility adjustments to the LCR   transitional arrangements for          increases would happen for at        detailing the steps it has taken to
                         requirement from 2.25% of RWA                          and NSFR frameworks and              expected loss provisioning and         least 18 months.                     support the resilience of financial
                         to 1% of RWA.                                          encouraged banks to utilize          provided guidance to the                                                    institutions.
                                                                                liquidity pools.                     application of IFRS9. They also                                             April 9: OSFI announced

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Provisioning, Definition of
                                                                                                                                                     Consultations/                   Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables              testing, conduct, etc.)
                                                                                                                    measures
                         March 13: OSFI set out an                                                        stated that loans subject to         March 13: OSFI said that it will    extensions of several regulatory
                         expectation that dividend                                                        payment deferral arrangements        suspend all consultations and new   filings.
                         increases and share buybacks                                                     will not be deemed as non-           policy development.                 April 16: OSFI released a
                         should be paused.                                                                performing.                          March 27: OSFI acknowledged         comprehensive FAQ to explain the
                         March 27: OSFI encouraged banks                                                  April 9: OSFI expressed their view   and adopted the revised BCBS        policy responses it has taken in
                         to use leverage ratio buffers and                                                that a maximum add-back of 70%       timetable for Basel III             regard to COVID-19.
                         announced transitional                                                           of allowances to Common Equity       implementation. Further they        June 8: OSFI further extended
                         arrangements for capital                                                         Tier 1 capital is appropriate for    announced that the                  2020 regulatory return
                         treatment of expected loss                                                       ECL accounting.                      implementation date for FRTB        implementation deadlines.
                         provisioning.                                                                    August 31: OSFI will gradually       and CVA will be delayed until       August 6: OSFI published a
                         March 30: OSFI determines                                                        phase out the special capital        January 2024.                       newsletter including plans to
                         capital treatment of loans to                                                    treatment of loan deferrals that     April 9: OSFI extended the          restart policy development and
                         SMEs under programs to support                                                   was provided to banks at the start   deadline for the implementation     consultations with the financial
                         COVID-19 efforts.                                                                of the pandemic.                     of the final two phases of the      sector.
                         April 9: OSFI temporarily excluded                                                                                    initial margin requirements for
                         central bank reserves and HQLA                                                                                        non-centrally cleared derivatives
                         sovereign-issued securities from                                                                                      by one year.
                         the leverage ratio exposure
                         measure.
                         April 9: OSFI is lowering the
                         capital floor factor from 75% to
                         70% until the domestic
                         implementation of the Basel III
                         capital floor expected in Q1 2023.
                         April 17: OSFI has released a
                         COVID-19-related explanatory
                         memo on Basel III and bank
                         capital, buffer utilization, and
                         related dividend restrictions.

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                  Page 15
Provisioning, Definition of
                                                                                                                                                                    Consultations/                  Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                    Default and NPL-related
                                                                                                                                                               Implementation Timetables             testing, conduct, etc.)
                                                                                                                                  measures
                         May 1: OSFI issued a letter stating
                         expectations on the use of Pillar II
                         capital buffers for DTIs using the
                         Standardized Approach to credit
                         risk.
                         June 23: OSFI announced that the
                         Domestic Stability Buffer will
                         remain at 1% of total risk-
                         weighted assets.
                         July 15: OSFI released a statement
                         supporting the recent statements
                         issued by the BCBS and the FSB
                         reinforcing the usability of banks'
                         capital buffers.
China                    *                                                      April 3: PBOC will cut the required   *                                    *                                    *
                                                                                reserve ratio for small and
                                                                                medium banks by 1% with
                                                                                reductions of 0.5% on both April
                                                                                15 and May 15.
                                                                                April 7: PBOC released an FAQ on
                                                                                targeted reserve ratio
                                                                                requirement cuts.
Finland                  March 16: FIN-FSA confirmed that                       March 16: FIN-FSA confirmed that      April 6: FIN-FSA announced that it   March 24: FIN-FSA extended time      June 25: FIN-FSA confirmed that
                         banks are temporarily exempt                           banks are temporarily exempt          will comply with EBA standards on    for reporting by non-life and life   only parts of the EBA Guidelines
                         from fulfilling certain additional                     from fulfilling certain additional    legislative and non-legislative      insurance companies.                 published June 2 on additional
                         capital requirements.                                  liquidity requirements.               moratoria on loan repayments.        June 29: FIN-FSA will comply with    reporting and disclosure
                         March 17: FIN-FSA lowered bank                                                               May 7: FIN-FSA clarified that        the EBA’s extension of payment       requirements in the context of
                         capital requirements by 1% by                                                                adoption of a transitional                                                COVID-19 will be mandatory.

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Provisioning, Definition of
                                                                                                                                                     Consultations/                   Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                Implementation Timetables              testing, conduct, etc.)
                                                                                                                    measures
                         removing the systemic risk buffer                                                provision under the CRR may be       moratoria deadlines to September   July 3: FIN-FSA said that in line
                         and adjusting bank-specific                                                      used to mitigate the impact of       30.                                with an earlier ESMA decision, the
                         requirements of all credit                                                       expected credit-loss provisioning                                       net short position reporting
                         institutions.                                                                    under IFRS 9 on CET1.                                                   threshold remains at 0.1%.
                         March 17: FIN-FSA will closely                                                   August 20: FIN-FSA announced it
                         monitor that banks use the                                                       has applied the updated EBA
                         positive effects of measures to
                                                                                                          guidelines on legislative and non-
                         mitigate the impact of the crisis
                                                                                                          legislative moratoria on loan
                         and not to channel them into the
                         payment of dividends or                                                          repayments.
                         performance bonuses.
                         March 30: FIN-FSA issued a
                         recommendation to supervised
                         banks to refrain from dividend
                         distributions until October 1.
                         April 6: FIN-FSA decided to
                         remove the additional capital
                         requirement of the systemic risk
                         buffer for certain banks in
                         addition to other systemically
                         important institutions.
                         June 29: FIN-FSA decided to
                         maintain the countercyclical
                         capital buffer rate at 0.0% and
                         relaxed the residential mortgage
                         loan cap.
                         July 29: FIN-FSA extended the
                         validity of its profit distribution
                         recommendation that credit

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Provisioning, Definition of
                                                                                                                                                        Consultations/             Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity      Default and NPL-related
                                                                                                                                                   Implementation Timetables        testing, conduct, etc.)
                                                                                                                    measures
                         institutions under its supervision
                         do not pay or commit to pay
                         dividends or other profit
                         distributions until January 1,
                         2021. The recommendation also
                         applies to repurchases and
                         redemptions of shares.
                         September 30: FIN-FSA decided to
                         maintain the countercyclical
                         capital buffer rate at 0% and kept
                         the loan caps unchanged.
France                   March 18: French authorities to                        *                         April 7: AMF clarified accounting    *                               March 17: AMF announced a
                         reduce the countercyclical capital                                               standards for calculation of                                         short selling ban for one month.
                         buffer from 0.25% RWA to 0%                                                      expected credit losses in light of                                   April 8: AMF has published a
                         RWA in accordance with the ECB                                                   recent announcements from                                            statement clarifying appropriate
                         proposal.                                                                        ESMA, EBA, and IASB.                                                 fund and risk management
                         March 30: ACPR called on credit                                                                                                                       protocols for asset managers
                         institutions under its direct                                                                                                                         during the COVID-19 crisis.
                         supervision and finance                                                                                                                               April 9: ACPR announces a
                         companies to refrain from                                                                                                                             relaxation of the reporting
                         distributing dividends or                                                                                                                             conditions for the banking sector.
                         undertaking buybacks until at                                                                                                                         April 15: AMF announced the
                         least October 1.                                                                                                                                      extension of the net short
                         April 1: High Council for Financial                                                                                                                   position ban until May 18, 2020
                         Stability lowered the                                                                                                                                 and issued an FAQ to clarify
                         countercyclical capital buffer to                                                                                                                     details of the ban.
                         0% as of 2 April.

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Provisioning, Definition of
                                                                                                                                                               Consultations/                         Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                 Default and NPL-related
                                                                                                                                                          Implementation Timetables                    testing, conduct, etc.)
                                                                                                                               measures
                         July 28: ACPR called on financial                                                                                                                                        May 18: AMF suspended the ban
                         institutions to follow the ESRB’s                                                                                                                                        on the creation or increase of net
                         recommendations on                                                                                                                                                       short positions.
                         distributions of dividends,
                         variable compensation, and share
                         buybacks.
Germany                  March 18: Deutsche Bundesbank                          March 20: BaFin announced in its     March 27: BaFin and Deutsche        April 2: BaFin and Deutsche              March 19: BaFin clarified the
                         announced that BaFin intends to                        FAQs that liquidity buffers can be   Bundesbank shared the view that     Bundesbank postponed the stress          scope of prohibitions on short-
                         lower the countercyclical capital                      used without any approval of the     the current situation does not      test for less-significant institutions   selling.
                         buffer from 0.25% to 0% as of                          supervisors in the current stress    lead to an undifferentiated,        planned for 2021 to 2022.
                         April 1.                                               situation as foreseen in the         automatic transfer of financial
                         March 24: BaFin recommends                             regulation.                          instruments from Level 1 to Level
                         firms pause share buybacks and                                                              2 or Stage 3.
                         carefully consider dividends and
                         bonuses.
                         March 30: BaFin confirmed that
                         they expect banks to not pay any
                         dividends or distribute profits
                         until at least October 2020.
                         March 31: BaFin issued a general
                         order to reduce the quota for
                         domestic countercyclical capital
                         buffer from 0.25 percent to 0
                         percent as of April 1.
                         August 4: BaFin reiterated its
                         position on dividend payments.
                         September 21: BaFin will let less
                         significant institutions under its
                         supervision exclude certain

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Provisioning, Definition of
                                                                                                                                                                  Consultations/                      Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                   Default and NPL-related
                                                                                                                                                             Implementation Timetables                 testing, conduct, etc.)
                                                                                                                                 measures
                         exposures to central banks from
                         the leverage ratio.
Hong Kong                March 16: HKMA lowered the                             April 3: HKMA announced                March 30: HKMA announced that        March 30: HKMA said it would          April 7: HKMA issued a letter on
                         counter-cyclical buffer level from                     measures to increase the banking       it is in discussions with relevant   defer Basel III implementation in     AML/CFT measures during COVID-
                         2.0% to 1.0% to support banks in                       sector’s liquidity and encouraged      bodies about the application of      line with BCBS’s updates.             19.
                         extending credit facilities to                         banks to use their liquidity buffers   expected credit loss provisioning    March 31: SFC said it is extending    April 21: SFC released a statement
                         customers.                                             even if their LCRs fall below the      requirements and expects to          the implementation deadlines of       on its commitment to providing
                         July 7: HKMA announced that the                        requirement.                           make a further announcement          certain intermediary regulations.     regulatory relief during COVID-19.
                         countercyclical capital buffer                         April 3: HKMA said the current         soon.                                May 7: SFC will postpone the          April 22: HKMA decided to
                         remains unchanged at 1.0%.                             level of regulatory reserves will be   April 8: HKMA decided to lower       implementation of initial margin      postpone the 2020 Supervisor-
                                                                                reduced by half.                       the regulatory reserve               requirements for non-centrally        Driven Stress Test until 2021.
                                                                                                                       requirement used for provisioning    cleared over-the-counter
                                                                                                                       by 50% with immediate effect.        derivative transactions by one
                                                                                                                       May 25: HKMA clarified its           year, in line with IOSCO and BCBS.
                                                                                                                       expectation on treatment of          May 25: HKMA will defer the final
                                                                                                                       expected credit loss provisioning.   two implementation phases of
                                                                                                                                                            margin requirements for non-
                                                                                                                                                            centrally cleared OTC derivatives
                                                                                                                                                            by an additional year until 1
                                                                                                                                                            September 2022.
India                    March 27: Reserve Bank of India                        March 27: Reserve Bank of India        April 17: Reserve Bank of India      April 17: Reserve Bank of India       March 20: SEBI announced
                         decided to maintain current                            decided to defer the                   permitted to grant a moratorium      outlined detailed instructions        regulatory measures including
                         minimum capital conservation                           implementation of the Net Stable       of three months on payment of all    relating to extension of resolution   position limits on stocks and
                         ratios until September 30 with the                     Funding Ratio to October 1.            term loan instalments falling due    timelines.                            derivatives.
                         last tranche of the capital                            April 17: Reserve Bank of India        between March 1 and May 31 and       May 23: Reserve Bank of India         April 20: SEBI decided that the
                         conservation buffer delayed to                         announced to reduce Statutory          clarified to exclude from the        further extended timelines for        measures implemented since
                         September 30. The pre-specified                        Liquidity Ratio (SLR) by 18% and       number of days past-due for the      resolution review.                    March 23, 2020 will continue to
                         trigger for loss absorption through                    increase Marginal Standing             purpose of asset classification.                                           be in force till May 28, 2020.
                         conversion/write-down of                               Facility to 3%, permit SLR-eligible

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Provisioning, Definition of
                                                                                                                                                                Consultations/                   Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                Default and NPL-related
                                                                                                                                                           Implementation Timetables              testing, conduct, etc.)
                                                                                                                              measures
                         Additional Tier 1 instruments will                     assets to be recognized as HQLA,    They also issued guidance on                                             April 29: Reserve Bank of India
                         remain at 5.5% of RWA until                            and allow banks to operate under    provisioning.                                                            provided a list of regulatory
                         September 30.                                          100% Liquidity Coverage Ratio for   May 23: Reserve Bank of India                                            returns which can be submitted
                         April 1: Reserve Bank of India said                    certain period.                     extended the moratorium on                                               with a delay of a maximum of 30
                         it will not activate the                               September 29: Reserve Bank of       payment of term loans by another                                         days from the due date.
                         countercyclical capital buffer.                        India decided to defer the          three months.                                                            May 22: SEBI announced it would
                         April 17: Reserve Bank of India                        implementation of NSFR              August 6: Reserve Bank of India                                          extend the regulatory measures
                         decided that all banks shall not                       guidelines until April 1, 2021.     confirmed asset classifications                                          implemented on March 23, 2020
                         make any further dividend                                                                  and provisioning under the                                               until June 25, 2020.
                         payouts from the profits                                                                   Resolution Framework for COVID-                                          June 18: SEBI announced it would
                         pertaining to the financial year                                                           19-related Stress.                                                       extend the regulatory measures
                         ended March 31, 2020 until                                                                                                                                          announced on March 20, 2020 to
                         further instructions.                                                                                                                                               July 30, 2020.
                         June 21: Reserve Bank of India                                                                                                                                      July 21: SEBI announced it would
                         assigned 0% risk weights to the                                                                                                                                     extend the regulatory measures
                         Guaranteed Emergency Credit                                                                                                                                         announced on March 20, 2020 to
                         Line under the Emergency Credit                                                                                                                                     August 27, 2020.
                         Line Guarantee Scheme.
                         September 29: Reserve Bank of
                         India decided to defer the
                         implementation of the last
                         tranche of 0.625% of the Capital
                         Conservation Buffer from
                         September 30, 2020 to April 1,
                         2021.
Indonesia                May 28: OJK announced Credit                           April 14: Bank Indonesia raised     April 16: OJK issued guidelines for   March 23: OJK extended the         March 23: OJK prohibits short
                         Treatment / Restructuring                              the Macroprudential Liquidity       accounting treatment, especially      submission deadlines for certain   selling transactions from March 2
                         Financing in accordance with POJK                      Buffer by 200 basis points for      in the application of Financial       reports by two months.             until at a specified date
                         Stimulus is excluded from the                                                              Instruments and Fair Value            March 31: Bank Indonesia relaxed   determined by the OJK.
                                                                                                                    Measurement.                          mandatory reporting for

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Provisioning, Definition of
                                                                                                                                                              Consultations/                 Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                 Default and NPL-related
                                                                                                                                                         Implementation Timetables            testing, conduct, etc.)
                                                                                                                               measures
                         calculation of low-quality assets                      conventional commercial banks,                                       commercial banks and all other
                         or Loans at Risk (LAR).                                beginning May 1.                                                     parties effective from 31st March
                         May 28: OJK temporarily removed                        May 28: OJK temporarily relaxed                                      2020 until a date yet to be
                         the obligation to fulfill the 2.5%                     obligations to fulfill Liquidity                                     determined.
                         Capital Conservation Buffer for                        Coverage Ratio (LCR) and Net                                         May 28: OJK postponed the
                         certain banks until March 31,                          Stable Funding Ratio (NSFR) for                                      implementation of Basel III
                         2021.                                                                                                                       Reforms to January 1, 2023.
                                                                                certain banks as low as 85% by
                                                                                March 31, 2021. Banks are
                                                                                required to prepare action plans
                                                                                to return the fulfillment of LCR
                                                                                and NSFR to 100% no later than
                                                                                30 April 2021.
Italy                    March 20: Banca d’Italia                               March 20: Banca d’Italia           *                                 *                                   March 17: CONSOB prohibited
                         confirmed all banks and non-bank                       confirmed all banks and non-bank                                                                         short selling on the entire Stock
                         intermediaries are allowed to                          intermediaries are allowed to                                                                            Exchange list.
                         operate temporarily below the                          operate temporarily below the                                                                            March 20: Banca d’Italia extended
                         level of the Pillar 2 Guidance and                     liquidity coverage ratio.                                                                                deadlines of reporting obligations.
                         the capital conservation buffer.                                                                                                                                April 15: CONSOB further
                         March 27: Banca d’Italia                                                                                                                                        suspended all regulation related
                         recommended that, at least until                                                                                                                                to COVID until May 11, 2020.
                         October 1, all banks and banking                                                                                                                                April 22: Banca d’Italia issued a
                         groups under its supervision will                                                                                                                               number of updates on supervisory
                         not pay out any dividends and will                                                                                                                              reporting obligations.
                         not take on any irrevocable                                                                                                                                     May 18: CONSOB suspended the
                         commitments regarding the                                                                                                                                       ban on creating net short
                         payment of dividends for the                                                                                                                                    positions or increasing existing
                         financial years 2019 and 2020;                                                                                                                                  net short positions.
                         and will refrain from carrying out

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Provisioning, Definition of
                                                                                                                                                           Consultations/                       Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                 Default and NPL-related
                                                                                                                                                      Implementation Timetables                  testing, conduct, etc.)
                                                                                                                               measures
                         share buy-backs aimed at
                         remunerating shareholders.
                         March 27: Banca d’Italia has
                         maintained the countercyclical
                         buffer rate at 0% for Q2 of 2020.
                         July 26: Banca d’Italia will keep
                         the countercyclical buffer rate at
                         0% for Q3 of 2020.
                         July 28: Banca d’Italia updated its
                         dividend restrictions and buffer
                         policies to be in line with the
                         ECB’s recommendations.
Japan                    March 17: JFSA confirmed banks                         March 17: JFSA confirmed a         *                                 March 30: JFSA announced the           March 30: JFSA confirmed a
                         can use capital buffers when                           flexible approach to banks                                           consideration of deferral of its       flexible approach to banks filing
                         necessary to maintain lending                          breaching the liquidity coverage                                     Basel III implementations              deadline.
                         volume.                                                ratio.                                                               schedule, in line with BCBS’s          August 31: JFSA published a
                         March 17: JFSA confirmed that                                                                                               recent update. Also confirmed          summary of its priorities for July
                         certain rescue lending activity                                                                                             that Net stable funding ratio will     2020-June 2021 in light of COVID-
                         would be risk-weighted at 0%.                                                                                               not be implemented for at least a      19.
                         April 8: JFSA and BOJ have agreed                                                                                           year.
                         to develop measures to                                                                                                      April 14: JFSA will extend deadline
                         temporarily exclude central bank                                                                                            for contracts for Settlement Agent
                         deposits from the leverage ratio                                                                                            for Bank’s Electronic Settlement
                         exposure measure.                                                                                                           System until the end of
                         April 17: JFSA proposed to                                                                                                  September if they have shown
                         remove central bank reserve from                                                                                            their will to settle contract by end
                         the calculation of leverage ratio                                                                                           of May.
                         and maintain the current ratio.                                                                                             April 15: JFSA said companies can
                                                                                                                                                     defer annual meetings in relation
                                                                                                                                                     to the recent announcement of

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                             Page 23
Provisioning, Definition of
                                                                                                                                                                   Consultations/                       Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                  Default and NPL-related
                                                                                                                                                              Implementation Timetables                  testing, conduct, etc.)
                                                                                                                                measures
                                                                                                                                                             the revision of the Cabinet Office
                                                                                                                                                             Order on Disclosure of Corporate
                                                                                                                                                             Affairs which will extend the filing
                                                                                                                                                             deadline of annual and quarterly
                                                                                                                                                             securities reports, etc. to the end
                                                                                                                                                             of September.
                                                                                                                                                             April 15: JFSA proposed to defer
                                                                                                                                                             the implementation of the final
                                                                                                                                                             two phases of the margin
                                                                                                                                                             requirements for non-centrally
                                                                                                                                                             cleared derivatives.
Mexico                   March 31: CNBV issued                                  April 8: CNBV relaxed certain         March 25: CNBV issued special          March 26: CNBV suspended               *
                         recommendations for banking                            liquidity rules, by deciding that     accounting criteria, applicable to     hearings and procedures during
                         institutions to refrain from                           banks can register as liquid assets   institutions of credit. The support    March 23 to April 19.
                         agreeing to the payment of                             those that had been eligible for      will consist of the partial or total   April 8: CNBV announced a delay
                         dividends, share repurchases, or                       the Liquidity Coverage Ratio (LCR)    deferral of capital and/or interest    in the implementation of
                         any other mechanism tending to                         until February 28 and will also       payments for up to 4 months.           regulatory standards including
                         reward shareholders.                                   grant some exceptions for             April 8: CNBV said it will delay the   Business Indicator Method and
                         April 8: CNBV will grant                               corrective measures if a bank’s       implementation of IFRS9 to             TLAC requirements.
                         temporary regulatory flexibility                       LCR falls below 100%.                 January 1, 2022.                       April 8: CNBV announced that it
                         until March 31, 2021 so that                           September 23: CNBV extended           April 15: CNBV issued                  will extend certain reporting
                         banks can use their capital                            liquidity requirements until March    adjustments to the special             deadlines.
                         buffers.                                               2021, with which banks will be        accounting criteria and extended
                         September 23: CNBV extended                            able to temporarily reduce their      the target of its treatment for
                         flexibility on the use of the capital                  liquidity buffers below 100%.         credit institutions.
                         buffer until December 31, 2021.                                                              April 27: CNBV issued special
                                                                                                                      accounting criteria and
                                                                                                                      information on loan modifications
                                                                                                                      for savings and credit institutions.

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                                   Page 24
Provisioning, Definition of
                                                                                                                                                       Consultations/                    Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity             Default and NPL-related
                                                                                                                                                  Implementation Timetables               testing, conduct, etc.)
                                                                                                                           measures
                                                                                                                 September 23: CNBV announced
                                                                                                                 a new package of measures for
                                                                                                                 credit restructuring.
Netherlands              March 17: DNB said that systemic                       March 20: DNB allowed banks to   April 24: DNB guided banks to   March 17: DNB announced that        March 16: AFM concurs with the
                         buffers will be lowered from 3%                        temporarily operate below the    avoid excessively procyclical   the introduction of a floor for     ESMA decision to temporarily
                         of global risk-weighted exposures                      liquidity coverage ratio.        assumptions in their expected   mortgage loan risk weighting will   requiring the holders of net short
                         to 2.5% for ING, 2% for Rabobank                                                        credit loss (ECL) estimations   be postponed.                       positions to notify the relevant
                         and 1.5% for ABN Amro.                                                                  during the COVID-19 pandemic                                        national competent authority.
                         March 17: DNB emphasized that                                                                                                                               March 27: AFM announced it
                         banks use freed-up capital to                                                                                                                               would exercise forbearance for
                         support lending, and not to pay                                                                                                                             delayed financial reports, in
                         dividend or share repurchases.                                                                                                                              accordance with ESMA
                         March 20: DNB allowed banks to                                                                                                                              recommendations.
                         temporarily operate below the                                                                                                                               April 16: DNB extended
                         level of capital as defined by the                                                                                                                          submission deadlines for certain
                         Pillar 2 Guidance and the capital                                                                                                                           supervisory reporting.
                         conservation buffer.
                         March 20: DNB stated that Pillar 2
                         Requirements can partially be met
                         by capital instruments that do not
                         qualify as Common Equity Tier 1
                         capital.
                         March 23: DNB deferred extra
                         capital requirement for mortgage
                         loans until further notice.
                         May 12: DNB clarified treatment
                         for real estate valuation and
                         capital requirements.
                         May 27: DNB extended temporary
                         relief measure for internal model

iif.com © Copyright 2020. The Institute of International Finance, Inc. All rights reserved.                                                                                                                       Page 25
Provisioning, Definition of
                                                                                                                                                                  Consultations/                     Other (reporting, stress
 Jurisdiction                                Capital                                          Liquidity                   Default and NPL-related
                                                                                                                                                             Implementation Timetables                testing, conduct, etc.)
                                                                                                                                 measures
                         capital requirements for market
                         risk.
                         June 19: DNB has decided to leave
                         the CCyB unchanged at 0%.
                         July 6: DNB supported the ESRB’s
                         recommendation that investment
                         firms limit distributions.
                         July 28: DNB extended its call for
                         banks to refrain from paying
                         dividends and buying back own
                         shares in accordance with ECB’s
                         announcement.
                         September 17: DNB said it will
                         give leverage ratio flexibility to
                         smaller banks under its
                         supervision, in line with the ECB.
                         September 25: DNB left the CCyB
                         unchanged at 0%.
Norway                   March 13: Ministry of Finance                          March 13: Finanstilsynet               April 3: Finanstilsynet provided     June 15: Finanstilsynet              March 13: Finanstilsynet
                         lowered the countercyclical                            confirmed companies can use the        guidance on treatment of IFRS9.      postponed the implementation of      announced postponement of
                         capital buffer level from 2.5% to                      liquidity reserve to cover liquidity   April 3: Finanstilsynet explained    SREP to 2021 and decided not to      certain reporting deadlines.
                         1.0% to support banks in                               output in a stress situation.          the EBA guideline on non-            make new Pillar 2 decisions in the   June 11: Finanstilsynet decided to
                         extending credit facilities to                                                                performing loans and clarified       second half of 2020.                 extend the lower threshold for
                         customers.                                                                                    that though no moratoriums are                                            reporting net short positions
                         March 13: Norges Bank said that                                                                                                                                         (0.1%) for three months in
                                                                                                                       in Norway, the guideline can be
                         when banks’ general meetings                                                                                                                                            accordance with ESMA.
                                                                                                                       applied to companies operating in
                         decide on dividend payments,                                                                                                                                            June 23: Finanstilsynet decided
                         they should in the period ahead                                                               countries with moratoriums.                                               not to implement the EBA
                         take account of the extraordinary                                                             April 20: Finanstilsynet specified                                        guideline on reporting published
                         situation now facing.                                                                         how the capital requirement                                               on June 2.

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